Notional Interest rates on Equity for the year 2019

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Article 9(B) of the Income Tax Law 2002 (as amended) provides for a notional interest deduction for tax purposes on new equity capital (paid-up share capital and share premium) injected into companies and permanent establishments of foreign companies on or after 1 January 1 2015 to finance business assets, calculated by applying a reference rate to the new equity.

The reference rate is the higher of the 10-year government bond yield of Cyprus or the country in which the assets funded by the new equity are used, in each case plus three percentage points. The bond yield rates to be used are as of December 31 of the year preceding the year of assessment.

The Cyprus Tax Department published on 30 January 2019 the 10-year government bond yields as of 31 December 2018, which will be used as the basis for the notional interest deduction for the 2019 tax year, for the following countries.

The rates are as follows:

10-year bond rate

Reference rate for 2019

Armenia

6.385

9.385

Austria

0.484

5.302

Belarus (USD)

7.226

10.226

British Virgin Islands

N/A

5.302

Bulgaria

0.966

5.302

Canada

1.965

5.302

China

3.261

6.261

Croatia

2.415

5.415

Cyprus

2.302

5.302

Czech Republic

1.884

5.302

France

0.705

5.302

Germany

0.284

5.302

Greece

4.346

7.346

Hong Kong

1.946

5.302

Hungary

2.971

5.971

India

7.261

10.261

Ireland

1.166

5.302

Italy

2.739

5.739

Kazakhstan

N/A

5.302

Latvia

1.029

5.302

Luxembourg

0.522

5.302

Mauritius

5.38

8.38

Netherlands

0.383

5.302

Norway

1.754

5.302

Poland

2.812

5.812

Romania

4.811

7.811

Russia

8.72

11.72

Russia (USD)

5.02

8.02

Serbia

4.722

7.722

Slovakia

0.789

5.302

Slovenia

1.166

5.302

South Africa

9.206

12.206

Spain

1.413

5.302

Sweden

0.457

5.302

Switzerland

-0.197

5.302

Ukraine (USD)

10.78

13.78

United Kingdom

1.275

5.302

USA.

2.685

5.685